ABSTRACT

WATER QUALITY INTERNSHIP WITH THE OHIO ENVIRONMENTAL PROTECTION AGENCY

Lemuel Alejandro Del Valle

During the summer of 2015 I had the opportunity to intern at the Ohio Environmental Protection Agency. I worked in the Central District Office in the Division of Surface Water in Columbus, Ohio. My responsibilities were focused around water quality monitoring of various lakes and streams within the state. Lakes sampled included Buckeye Lake, Grand Lake St. Marys, other lakes within the Ohio State Parks system, and drinking water reservoirs. Streams were sampled for varying projects including ambient water quality sampling. The other part of my internship dealt with storm water inspections at construction sites within the Central EPA District. Inspections determined compliance with the general construction permit. This meant assessing sediment and erosion controls and how these controls were implemented for each site. The various types of water quality monitoring will be used to address pressing water quality issues such as nutrient loading and harmful algal blooms, wastewater discharge, and sediment pollution.

WATER QUALITY INTERNSHIP WITH THE OHIO ENVIRONMENTAL PROTECTION AGENCY

An Internship Report

Submitted to the

Faculty of Miami University

in partial fulfillment of

the requirements for the degree of

Master of Environmental Science

Institute of the Environment and Sustainability

by

Lemuel Alejandro Del Valle

Miami University

Oxford, Ohio

2016

Advisor: Sarah Dumyahn

Reader: Jonathan Levy

Reader: Bartosz Grudzinski

This Internship Report Titled

WATER QUALITY INTERNSHIP WITH THE OHIO ENVIRONMENTAL PROTECTION AGENCY

by

Lemuel Alejandro Del Valle

has been approved for publication by

The College of Arts and Science

and

Department of the Institute for the Environment and Sustainability

Sarah Dumyahn

Jonathan Levy

Bartosz Grudzinski

Table of Contents Table of Contents ...... iii List of Tables ...... iv List of Figures ...... v Acknowledgments...... vi Chapter 1: Introduction and Background ...... 1 Harmful Algal Blooms ...... 1 The Clean Water Act and Nutrient Pollution ...... 2 Ohio Environmental Protection Agency Background ...... 3 Ohio EPA Division of Surface Water ...... 6 Chapter 2 Buckeye Lake and Grand Lake St. Marys ...... 9 Buckeye Lake History ...... 9 Buckeye Lake Dam ...... 11 Grand Lake St. Marys History ...... 11 Ohio EPA Water Quality Monitoring at Buckeye Lake and Grand Lake St. Marys ...... 13 Chapter 3 Inland Lakes & Tetra Tech Study ...... 17 Tetra Tech ...... 22 Lake Alma ...... 23 Kiser Lake ...... 26 Rose Lake ...... 29 Drinking Water Reservoirs ...... 29 Chapter 4 Other Water Quality Projects ...... 30 Storm Water ...... 30 General Permit OHC000004 ...... 32 Antidegradation Categories ...... 34 Ambient Water Quality Monitoring ...... 36 Biomonitoring ...... 37 Chapter 5 Reflection on IES Experience ...... 39 Appendix A ...... 44 Appendix B ...... 46 Regular Letter Template ...... 46 No Construction Template ...... 47 Notice of Termination Template ...... 49 References ...... 51

iii List of Tables

Table 1 Ohio Designated Uses and Subcategories ...... 3 Table 2 Ohio Divisions and Offices in alphabetical order ...... 4 Table 3 Parameters analyzed in water column samples ...... 15 Table 4 Sample Locations ...... 15 Table 5 Parameters measured for Water Chemistry ...... 16 Table 6 Sample Locations ...... 16 Table 7 Tetra Tech Study Lakes and Locations ...... 22 Table 8 Permanent Stabilization ...... 33 Table 9 Temporary Stabilization ...... 33 Table 10 Overview of key knowledge and skills obtained from the Ohio EPA internship .... 39

iv

List of Figures

Figure 1 District Offices. …………………………………………………………………………………………………5 Figure 2 Organization of the Central District Office Division of Surface Water ...... 6 Figure 3 Overview of the water quality focal areas during my internship with the Ohio EP.. 8 Figure 4 Buckeye Lake ...……………………………………...……………………………………………….……….10 Figure 5 Grand Lake St. Marys ………………………………………..…………………………....……………….12 Figure 6 Using a tube sampler in Buckeye Lake ……………………………………………………………..20 Figure 7 Samples composited in a churn splitter on Buckeye Lake………………………………….21 Figure 8 Lake Alma State Park ………………………………………………………………………………………24 Figure 9 Kiser Lake State Park ...... 26 Figure 10 State Resource Waters 2015 Sampling Site……………………………………………………..35 Figure 11 2015 Ambient Sampling Sites ...... 37

v Acknowledgments

I would like to thank my major professor on this internship report, Dr. Sarah Dumyahn, for her continuous support and understanding throughout the writing process. I was thinking clearly the day I asked for her help and I am happy to have done so. This report and I have only benefitted from her wisdom and helpfulness.

I would also like to thank Dr. Jonathan Levy and Dr. Bartosz Grudzinski as committee members. They have provided me with insight and valuable perspectives that held this report to a high standard.

Additionally, I would like to thank the Central District Office, Division of Surface Water of the Ohio Environmental Protection Agency. I want to thank Jeff Lewis, Jeff Bohne, Eric Saas, and Mike Gallaway. Without their experience and teachings I would have little to write. They have provided me with all the information I needed and were always willing to help.

Last but not least I would like to thank my family and friends for their support. It is comforting to know that there is a support system always behind you ready to help on a moment’s notice.

vi Chapter 1: Introduction and Background

I completed an internship with the Ohio Environmental Protection Agency’s Division of Surface Water during June to October 2015. This report describes the water quality issues, such as harmful algal blooms, and the regulations that relate to my internship responsibilities. Additionally, the report addresses the primary projects that I participated in and the protocols and methods that were used for these projects. Harmful Algal Blooms

Key elements needed for life in small concentrations are known as nutrients. Phosphorus and nitrogen are two of these elements and when found in excess lead to nutrient enrichment or eutrophication (Braig et al., 2010). Eutrophication associated with global human populations has been linked to algal blooms (O’Neil, 2012). Algal blooms, or an abundance of growing algae, are not necessarily composed of true eukaryotic algae and are often times not. These blooms can be formed by prokaryotes, specifically cyanobacteria, also commonly referred to as blue-green algae (Braig et al., 2010; O’Neil, 2012). Blooms formed by cyanobacteria have the potential to produce toxins that can cause harm to other organisms and are referred to as harmful algal blooms (HABs) (Braig et al., 2010).

HABs have been identified across Ohio as they can occur in a range of water bodies as small as a retention pond to as large as Lake Erie (Braig et al., 2010). HABs are complex events and cannot be attributed to a single environmental driver but more likely a suite of contributing factors (O’Neil, 2012). Contributing factors are eutrophication, sunlight, shallow water, low flow conditions, lack of wave action, warmer temperatures, low salinity, and selective grazing (Braig et al., 2010). Many types of cyanobacteria have the ability to acquire and utilize nitrogen from the atmosphere. This ability allows them to flourish in systems with scarce nitrogen availability where other organisms like plants and true algae are poor competitors (Braig et al., 2010). This causes phosphorus to be the limiting nutrient for growth and therefore the primary control of eutrophication in many freshwater bodies (Braig et al., 2010; Kleinman et al., 2011). Not all of the bloom forming cyanobacteria are capable of fixing nitrogen out of the atmosphere so it is thought that both phosphorus and nitrogen are controls for HABs (O’Neil et al., 2011). Phosphorus that is released from lake sediment may be an important source and can be considered “legacy P” since it originates from past nutrient applications to soil (Kleinman et al., 2011).

HABs have many negative impacts including taste and odor issues with drinking water, beach pollution, loss of recreational use at water bodies, harm to tourism, reduced property value, oxygen level reduction for aquatic life, increased costs for treatment and testing associated with public water supplies, other organisms being outcompeted, and the production of toxins (Braig et al., 2010; Kilbert et al., 2012). Hepatotoxins, cyanobacterial toxins that target the liver, are globally the most common class of HAB toxin followed by neurotoxins, or toxins targeting nerve synapses and axons (O’Neil 2011). Drinking water contaminated with toxins produced by HABs has led to gastrointestinal problems, liver damage, neurological effects, and death

1 (Davenport and Drake 2011). Nontoxic blooms can still compromise the ecological structure and function and aesthetics of lakes (Michalak et al., 2013).

Lake Erie is the shallowest, most productive, and most southern of the Great Lakes (Michalak et al., 2013). These conditions and the other contributing factors mentioned previously led to a severe and record-breaking algal bloom mid July 2011(Michalak et al., 2013). The composition of the bloom was almost completely made up of Microcystis initially and then replaced by Anabaena sp. later in the season (Michalak et al., 2013). This bloom led to higher costs for cities and local governments, including Toledo, to treat drinking water. The bloom was also a nuisance and a potential risk for recreational activities (NOAA, 2015b). A severe bloom was predicted for 2015 about 0.87 times the severity seen in 2011 (or an 8.7 on the severity index) with severity peaking in September (NOAA, 2015b). Analysis has shown that the 2015 bloom was in fact the most severe this century. The severity index in 2015 was 10.5 as compared to 10 for the 2011 bloom, the second worst bloom recorded (NOAA, 2015a)

The Clean Water Act and Nutrient Pollution

Pollution into national and state waters is of increasing concern with recent HABs. Regulations and laws have been established to protect the health of these natural resources. The Ohio EPA and the Division of Surface Water exist in part to protect water resources made necessary by specific legislation such as the Clean Water Act.

Since harmful algal blooms are triggered by excess nutrients in lakes, laws that place limits on nutrient sources can help control HABs (Kilbert et al. 2012). The Clean Water Act is the primary law that regulates pollution into waters of the United States. The predecessor of the CWA was known as the Federal Water Pollution Control Act and was enacted in 1948. In 1972 the act was broadened and amended (U.S. EPA, “Summary of the Clean Water Act”). With this act, water quality standards were set for contaminants in surface waters. “The CWA made it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit was obtained” (U.S. EPA, “Summary of the Clean Water Act”). A point source is “any discernable, confined and discrete conveyance”, such as pipes, ditches, or channels (CWA). This term specifically excludes “agricultural storm water discharges and return flows from irrigated agriculture” (CWA). In this context, navigable waters include “the waters of the United States” (CWA). The exact boundaries of what constitutes waters of the United States is unclear but includes intermittent streams and waters with a significant nexus to larger, permanent water bodies (Kilbert et al. 2012).

Phosphorus is considered a pollutant in the CWA and discharges of pollutants to navigable waters are unlawful without a National Pollutant Discharge Elimination System. NPDES permit (Kilbert et al. 2012). The implementation of the CWA led to regulation of point source inputs and influenced agricultural practices, which ultimately led to the reduction of phosphorus input to Lake Erie. The HABs that had persisted from the 1960s and 1970s were essentially eliminated by 1980 (Kilbert et al. 2012). Discharges can be either categorized by being point source or nonpoint source. Point sources are typically regulated more than nonpoint sources, as nonpoint sources are more complex and difficult to control. The regulation of nonpoint sources has not been as effective as regulation of point sources. Nonpoint sources are

2 now the main source of phosphorus entering Lake Erie whereas point sources were greater in the past (Kilbert et al. 2012).

In Ohio, the U.S. EPA has delegated the authority to administer and enforce the NPDES program to the Ohio EPA. In this sharing of authority, Ohio EPA issues permits while the U.S. EPA retains oversight and veto authority (Kilbert et al. 2012). States that are delegated this authority must have laws at least as strict as the federal laws. In Ohio the Ohio Revised Code chapter 6111 is the main piece of legislation governing point source discharges into state waters. Ohio’s statute is broader than the CWA because it includes all waters of the state rather than just navigable waters (Kilbert et al. 2012). This means that discharges into groundwater or non- navigable surface waters that are not covered by the CWA may require a permit under Ohio law (Kilbert et al. 2012).

The effluent limit, or allowable volume and concentration of a pollutant, allowed under a NPDES permit is based upon two factors (Kilbert et al. 2012). The first factor is the technology- based control that the U.S. EPA has established for specific categories of dischargers of a certain industry (Kilbert et al. 2012). The second factor is the water quality standards of the receiving water body (Kilbert et al. 2012). Water quality standards set the maximum level of a pollutant that can legally exist in an ambient water body and are a function of the designated use of the water body and water quality criteria needed to protect the designated use (Kilbert et al. 2012).

Ohio EPA establishes the water quality standards for the state, which are subject to U.S. EPA approval. There are three designated uses in Ohio, each with subcategories (Table 1).

Table 1 Ohio Designated Uses and Subcategories (Ohio EPA, “Water Quality Standards Program”)

Aquatic Habitat Water Supply Recreation Warmwater Public Bathing Waters Limited Warmwater Agricultural Primary Contact Waters Exceptional Warmwater Industrial Secondary Contact Waters Modified Warmwater Seasonal Salmonid Coldwater Limited Resource Water

Ohio Environmental Protection Agency Background

The Ohio Environmental Protection Agency (Ohio EPA) was formed on October 23, 1972 (Ohio EPA, “About”). Environmental work was being accomplished before the creation of the Ohio EPA, but responsibilities were unfocused and spread over various other state and local agencies. During this transition, the Ohio Departments of Health and Natural Resources became the core of the newly formed Ohio EPA (Ohio EPA, “History”).

3 The establishment of the Ohio EPA falls within a period of environmental awareness and awakening for the United States. From 1969-1979 there were 27 environmental laws passed (Kubasek and Silverman, 2013). Multiple pollution events, including the Cuyahoga River catching on fire; several influential books, including Rachel Carson’s “Silent Spring”, were published or became popular in that time; and the induction of Earth Day on top of the political atmosphere after both the Civil Rights and antiwar movements all contributed to the rise of environmental policy and regulation.

The Ohio EPA is divided into several divisions and offices (Table 2). The Ohio EPA has a central office that is located in downtown Columbus and five district offices located throughout the state (Figure 1). An additional field office is located in Groveport. The central district office is also located in Columbus, the northeast district office is located in Twinsburg, the northwest in Bowling Green, the southwest in Dayton, and the southeast in Logan, Ohio.

Table 2 Ohio Divisions and Offices in alphabetical order (Ohio EPA, “About”)

Air Pollution Control Environmental Education Legal Services Compliance Assistance and Environmental and Finance Materials and Waste Pollution Prevention Assistance Management Director’s Office Environmental Response and Public Interest Center Revitalization Drinking and Ground Waters Environmental Services Special Investigations Employee Services Fiscal Administration Surface Water

The goal of the Ohio EPA is “to protect the environment and public health by ensuring compliance with environmental laws and demonstrating leadership in environmental stewardship” (Ohio EPA, “About”). Through its regulatory divisions, the “Ohio EPA establishes and enforces standards for air, water, waste management and cleanup of sites contaminated with hazardous substances” in addition to providing “financial assistance to businesses and the public; and pollution prevention assistance to help businesses minimize their waste at home” (Ohio EPA, “About”). The central office sets the policy for the state and the five district offices implement those policies. Within the district offices, the divisions issue permits to regulate industries in a specific environmental area (Ohio EPA, “About”). Other responsibilities that each division holds are to review permit applications, investigate complaints, monitor to make sure environmental standards are met, provide technical assistance to permit holders, and to take enforcement action against facilities that are not in compliance with environmental laws and permit requirements (Ohio EPA, “About”).

4 District Offices

Central Office Northwest District Office Northeast District Office Lazarus GovernmentFigure Center1 District Offices (Ohio EPA 347 N. Dunbridge Rd. , “District Offices”2110 E. Aurora Rd. ) 50 W. Town St., Suite 700 Bowling Green, OH 43402 Twinsburg, OH 44087 P.O. Box 1049 (419) 352-8461 (330) 963-1200 Columbus, OH 43215 (800) 686-6930 (800) 686-6330 (614) 644-3020

Central District Office Southeast District Office Southwest District Office Lazarus Government Center 2195 Front Street 401 E. Fifth St. 50 W. Town St., Suite 700 Logan, OH 43138 Dayton, OH 45402 Columbus, OH 43215 (740) 385-8501 (937) 285-6357 (614) 728-3778 (800) 686-7330 (800) 686-8930 (800) 686-2330

Toll-free numbers are for citizens with questions or concerns about environmental issues. The regulated community should use the business line for routine business. Spills and emergencies should be reported to (800) 282-9378.

5 Ohio EPA Division of Surface Water

My professional experience and internship was within the Central District Office (CDO) in the Division of Surface Water (DSW). As a whole, the DSW ensures compliance with the Clean Water Act. Their mission is to protect, enhance and restore all waters of the state for the health, safety, and welfare of present and future generations (Ohio EPA, “About”). Efforts are also made to increase the number of water bodies that can be safely used for swimming and fishing (Ohio EPA, “About”). The division also issues permits to regulate wastewater treatment plants, factories, and storm water runoff. Watershed plans are developed with the goal to improve polluted streams. Lastly, the division samples streams, lakes, and wetlands to determine the health of Ohio’s water bodies (Ohio EPA, “About”).

A goal of the DSW, restoration and maintenance of Ohio’s water resources reflects the national water quality objective in the Federal Clean Water Act. This goal is known as the “fishable/ swimmable goal” and aims “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters” (Ohio EPA, “Surface Water”). This goal is not only to maintain water for public and industrial water supplies, but to also allow for natural ecological functioning (Ohio EPA, “Surface Water”).

This office is made up about fifteen state employees who accomplish various activities. In CDO there are permitting, compliance and enforcement, and water quality/ storm water groups (Figure 2). Each sector has four environmental specialists under the supervisor.

Environmental Manager

Environmental Supervisor (Water Quality/ Storm Water)

Water Quality Engineer (Permitting) Environmental Supervisor (Compliance and Enforcement)

Figure 2 Organization of the Central District Office Division of Surface Water (Ohio EPA, “2015 Projects”)

Permitting consists of issuing National Pollutant Discharge Elimination System (NPDES) permits and permits-to-install (PTIs). NPDES permits are for municipal, or publicly owned waste

6 water treatment plants, and industrial, or processed industrial water and storm water discharging to waters of the state. On occasion, permitting personnel work issues indirect discharge permits for industries that discharge directly to a wastewater treatment plant (WWTP). PTIs cover sanitary sewer extensions, pump stations, WWTP upgrades, new WWTPs, and outside waste water disposal systems. The designs of the systems are in accordance with Ohio EPA rules and the 10 state standard, recommended standards for wastewater facilities. Staff also review plans for the disposal of sewage sludge from WWTP, review permit applications for industrial and construction sites, and provide assistance to dischargers of storm water from industrial and construction sites (Ohio EPA, “District Offices”).

The Ohio EPA staff assigned to compliance and enforcement responds to citizen complaints concerning stream pollution and improperly treated wastewater discharges and enforces the NPDES permits (Ohio EPA, “District Offices”). They monitor permit holding facilities’ discharge and conduct regular inspections of these facilities. Assistance is offered to facilities when found to be in violation. If no effort is put forth to comply, that is when enforcement is used. Each staff member has approximately seven major facilities that they inspect every year. The quantity of smaller facilities varies by county from 30-70 facilities per county. Inspections for smaller facilities have to take place at least once every five years, but in practice inspections typically happen more frequently with an inspection every 1-2 years. Complaints vary in number but are inspected every three months. Some members of the complaints and enforcement staff also write NPDES permits for the counties with fewer facilities, but in most other districts the same staff in the office usually does this. Other district offices usually do not have this distinction between permit writers and enforcement.

Water quality personnel are tasked with many activities. Ongoing monitoring programs assess inland lake water quality by sampling water chemistry and other biological parameters. Water quality data are collected from streams and other water bodies from a network of monitoring sites to establish a more complete categorization of usage and to update trends in surface water quality (Ohio EPA, “District Offices”). Data are compiled and analyzed for evaluation of water quality and to establish new limits for discharge permits as needed. Additionally, water quality and toxicity tests of permitted dischargers are conducted to determine permit compliance (Ohio EPA, “District Offices”). Water quality personnel also provide technical assistance on related issues to permit holders and other government agencies as well as support enforcement by case preparation, water sampling, and expert testimony (Ohio EPA, “District Offices”).

Storm water is the last group of the DSW. A primary task for Ohio EPA storm water employees is to inspect construction sites for compliance with the general permit for storm water discharges from large and small construction activities and provide technical assistance when appropriate. Permits are issued “that require the development of Storm Water Pollution Prevention Plans and the implementation of best management practices to control the quality of storm water runoff from sites with construction and industrial activities” (Ohio EPA, “District Offices”). Other activities include permitting and regulation of discharges from Ohio municipalities and the investigations of complaints (Ohio EPA, “District Offices”).

7 My summer internship was comprised of various components (Figure 3). As a whole, the Ohio EPA is responsible for the state compliance with the Clean Water Act. Without this regulatory system, the waters of Ohio would likely be compromised. Pollutants would not be regulated and the waters may not be usable as a resource and could no longer sustain the life within them.

Ohio EPA Internship Division of Surface Water Central District Ofice

Lake Water Quality Other Water Quality Hazardous Algal Tasks Blooms Monitoring Ambient Water Quality, Buckeye Lake & Grand Lake Alma, Kiser Lake & Biomonitoring & Storm Lake St. Marys Rose Lake Water Permits -Chapter 2 -Chapter 3 -Chapter 4

Figure 3 Overview of the water quality focal areas during my internship with the Ohio EPA

Lake sampling was a primary component of my internship responsibilities. I was able to participate in monitoring Buckeye Lake and Grand Lake St. Marys as part of the HAB monitoring program and Lake Alma, Kiser Lake and Rose Lake as part of Ohio EPA’s lake water quality monitoring program. Lake sampling allows for the continuation of monitoring the condition of certain lakes. Continued sampling allows for a more complete understanding of nutrient cycling and to track improvements in lake health. Stream sampling was another part of my internship and met many goals including monitoring reference sites, categorizing streams, and monitoring wastewater effluent. Stream sampling establishes the appropriate tiered antidegradation category for significant streams within several small watersheds in southern Ohio. Verification of the appropriate aquatic life use categorization is an additional benefit of this sampling.

Aside from lake sampling, this internship also provided me with more experience with storm water. Construction site inspections check compliance with the National Pollutant Discharge Elimination System (NPDES). NPDES permits limit the quantities of pollutants to be discharged and impose monitoring requirements and other conditions (Ohio EPA, “NPDES”). Storm water pollution associated with the active phase of construction focus on sediment and

8 erosion control, non-sediment pollution controls, and post construction storm water best management practices. The goal is to protect public health and the aquatic environment.

Chapter 2 Buckeye Lake and Grand Lake St. Marys

Buckeye Lake History

Buckeye Lake is a state owned reservoir located in Licking, Perry, and Fairfield counties in central Ohio (Ohio EPA, 2015a). It is roughly 30 miles east of downtown Columbus. The reservoir surface area at the top of the dam is 3,030 acres (ODNR, Buckeye Lake Dam). Buckeye Lake has been described before as an irregular body of water. Its longest diameter is from east to west and is approximately 7 miles long and varies in width from a quarter mile in the east to 1.5 miles in the western end (Detmers, 1912; Tressler, 1940). It drains approximately 45 square miles that flow in from the northeast, south, and west sides of the lake. Much of the water drained into Buckeye Lake comes through agricultural land used primarily for row-crop production with limited farm animal production (Ohio EPA, 2015a).

A dike was constructed from 1826 to 1830 that blocked drainage into the South Fork of the Licking River and formed what was then known as the Licking River Summit Reservoir (ODNR, “Buckeye Lake”). This effort was part of a larger project to develop a canal system in Ohio. At the end of the 19th century railroads were replacing canals across the country. Feeder reservoirs of the Ohio canal system were established as public parks by an 1894 state General Assembly of Ohio policy (ODNR, “Buckeye Lake”; Tressler, 1940). During this change, the Licking Summit Reservoir was renamed Buckeye Lake (ODNR, “Buckeye Lake”). The park became Buckeye State Park in 1949, when the Ohio Department of Natural Resources was created (ODNR, “Buckeye Lake”).

Detmers (1912) described this previously forested wetland as an “impassable swamp”. Most of the vegetation was left standing before the impoundment in the early 1800s. If aquatic plants were left undisturbed, they would take over the lake and render navigation impossible (Detmers 1912). Evidence of the previous wetland flora can be seen with the mats of sphagnum moss that were lifted with the rising water levels and created “floating islands” which can still be seen today. The largest island, Cranberry bog, is a state nature preserve and a National Natural Landmark and is described as a sphagnum peat bog. This floating island may be the only one of its kind in the world (ODNR, “Buckeye Lake”). In 1912, Detmers approximates the size of Cranberry bog to have an area of about 45 acres. It was noted that the island seemingly decreased in size every winter due to winter storms detaching outer lying edges of the island. Other islands are established on smaller pieces of peat. When the water is warm and the water level is low, gases created in the peat allow it to rise to the surface (Detmers, 1912). Established vegetation on masses that end up being exposed for multiple seasons create islands and grow by accumulating other masses and floating debris.

9

Figure 4 Buckeye Lake (ODNR Division of Wildlife)

High nutrient content was likely a part of this region ever since the most recent glaciation, which started approximately 24,0000 years ago and ended about 14,000 years ago (Hansen, 2008). As ice moved over the earth and remained in place for some time, a thicker ridge of till, or end moraine, was deposited along the ice edge. Belts of end moraines cover the state as ice advanced and receded (Hansen, 2008). Lakes known as kettles, formed in association with moraines when ice was deposited and left in the till. The melted ice left a depression. Many of these kettles have been filled with sediment and are represented today by swampy depressions. Other lakes were formed as glacial activity blocked existing water outlets (ODNR, “Buckeye Lake”). These glacial processes helped to form the wetlands that were eventually impounded to create Buckeye Lake and can explain many of the other swampy areas or wetlands across Ohio.

Inland water ecosystems, like Buckeye Lake, are not constant and evolve through time. This change is relatively quick for shallow, hyper eutrophic systems (Björk, 2010). Inland wetlands and shallow lakes are typically short-lived ecological units that eventually become filled with inorganic and organic material (Björk, 2010). Nutrient enrichment, or eutrophy, is an overwhelming problem for Buckeye Lake (EPA, 2015a). According to Björk (2010), there is an important change in productivity as a lake becomes shallow enough for macrophytes to establish themselves on the lake bottom. This change is the most productive phase in lake evolution

10 because of ample nutrients in the lake catchment, abundance of water, and macrophyte adaptation to these specific environmental conditions. Buckeye Lake has a tendency to return to it’s past wetland state despite being shifted back in the lake continuum.

Buckeye Lake Dam

One feature of Buckeye Lake State Park that has been garnering the attention of many people recently is the Buckeye Lake Dam. This dam is located near the edge of Millersport and the Village of Buckeye Lake in portions of Licking and Fairfield counties. The dam was created in the years 1825-1832 as an earthen embankment and measures about 4 miles long (ODNR, “Buckeye Lake Dam”). This dam is designated as a Class 1 high-hazard potential dam. This designation speaks to the adverse consequences that would occur in the case of dam failure rather than the dam’s condition (ODNR, “Buckeye Lake Dam”).

Buckeye Lake Dam was found to have several safety deficiencies and these shortcomings were documented in several Ohio Dam Safety reports and most recently in a March 2015 report created by the U.S. Army Corps of Engineers. It was found that the dam isn’t properly keeping water back as there are excessive long-term seepage and deterioration of the earthen embankment. Other deficiencies include instability of the dam from multiple excavations into the downstream slope, and portions of the dam that can’t be investigated since they are covered by structures (ODNR, “Buckeye Lake Dam”).

This work is necessary to ensure the safety of those that live around the dam, to protect Buckeye Lake and its future, and to allow ODNR to meet its legal and other obligations to the lake community (ODNR, “Buckeye Lake Dam”). Since April 2015, the lake has been kept at its usual winter operational level of 888.75 feet. The lake will be kept at this lower than usual level until the dam improvements are made. This operational level is 16 percent (about 3 feet) lower than its normal summer pool level. Possible impacts to water quality from the lower water levels are being monitored by the Ohio EPA as part of the larger water quality monitoring effort at Buckeye Lake.

Grand Lake St. Marys History

At 13,500 acres Grand Lake St. Marys is Ohio’s largest inland lake and was for many years recognized as the largest man-made reservoir in the world (ODNR, “GLSM”). It lies between the Auglaize and Mercer county line between St. Marys and Celina. The lake is approximately 9 miles long and 3 miles wide (ODNR Wildlife, “GLSM”). The lake is shallow with an average depth of 5 to 7 feet (Davenport and Drake, 2011). The Grand Lake watershed is 54,000 acres (or about 84 square miles), which is relatively small when compared to the lake’s surface area (Davenport and Drake, 2011). This watershed is dominated by agriculture and as a result the lake is prone to eutrophication (Steffen, 2014). The bottom of the lake is mostly soft and made of silt but some areas have sandy or clay bottoms where wave action is more prevalent (ODNR Wildlife, “GLSM”).

11 Figure 5 Grand Lake St. Marys (ODNR Division of Wildlife)

Ohio was once an untamed wilderness. A forest stretched from the Allegheny Mountains of Pennsylvania to the open prairies of Illinois. This wilderness has been largely removed and fragmented. Wetlands were another common feature of the Ohio past. The land beneath Grand Lake St. Marys was once a vast wet prairie (ODNR, “GLSM”).

The St. Marys River was an important resource lying in between Lake Erie and the Ohio River. This area was settled due to the proximity to the river and then later in 1837 a reservoir was to be built for the Miami-Erie canal (ODNR, “GLSM”). When completed in 1845 the lake was the largest man-made lake in the world. The lake was connected to the canal by a three-mile feeder. The canal did well until the coming of the railroad in the 1870s. Grand Lake St. Marys was the site of the first offshore drilling in the world (ODNR, “GLSM”). This region was also one of the first areas to be dedicated as an Ohio state park in 1949.

Many similarities exist between Grand Lake St. Marys and Buckeye Lake. Both of these lakes are man-made with the purpose to feed the canal system with water to maintain the working water level. These lakes were built on a type of preexisting wetlands. These water bodies both are impaired with similar problems as the watersheds they drain both have high agricultural land use. Runoff from agriculture leads to eutrophication. This eutrophication in turn leads to a prevalence of cyanobacterial blooms and HABs. These are both part of parks that were created at the same time when the General Assembly of Ohio when the feeder reservoirs were established as state parks.

12 In 2007, a National Lake Assessment (NLA) study conducted by the U.S. Environmental Protection Agency (U.S. EPA) and partners analyzed water quality for toxins in selected lakes. The highest levels of microcystin were found in Grand Lake St. Marys (GLSM). In May 2009, Ohio Environmental Protection Agency (Ohio EPA) found microcystin levels at four times the World Health Organization’s (WHO’s) threshold for recreation leading to posted signage directing people to avoid water contact (Davenport and Drake, 2011). 2010 brought even worse blooms than previously seen resulting in recreational, human health, and fish consumption advisories to be placed on GLSM (Davenport and Drake, 2011). This bloom of 2010 caused foul smelling scum and dead fish to wash on to shore as well as twenty-three cases of human illness and dog deaths (Davenport and Drake, 2011).

Ohio EPA Water Quality Monitoring at Buckeye Lake and Grand Lake St. Marys

Since the Lake Erie bloom in 2011, HABs have been a hot topic. As a result the Ohio EPA has continued to monitor nutrients in inland lakes to provide a better understanding on blooms and toxin generation. Both Buckeye Lake and Grand Lake St. Marys have a history of high nutrients and can provide useful information in this area.

The Ohio EPA has been involved with water quality monitoring at Buckeye Lake for several years. In 2015, a study plan was crafted to gather additional data on nutrient cycling and fate (Ohio EPA, 2015a). This study plan is titled the 2015 Buckeye Lake Nutrient Reduction Study. The goal of this continued monitoring was to maintain an ongoing record of lake water quality and to better understand how nutrients are moved within the system. Another benefit of water quality monitoring is to determine if the summer drawdown of the lake induced by the current dam construction is affecting water quality, which would subsequently inform lake management (Ohio EPA, 2015a). Similarly, the Ohio EPA has sampled Grand Lake St. Marys annually since 2010 (Ohio EPA, 2015b). In 2015 the objective of the study was to continue to monitor trends in lake water quality.

To determine water quality standards in lakes the Ohio EPA uses specific sampling procedures. Specifically the inland lake sampling procedure is used for most lake sampling (Ohio EPA, 2013b; Ohio EPA, 2015c). Buckeye Lake and Grand Lake are specialized projects with modified inland lake protocols. Water samples are taken and are analyzed for a specific inland lake parameter template. Base parameters analyzed include total alkalinity, ammonia, carbonate/ bicarbonate, chloride, metals (Al, Ba, Ca, Fe, Mg, Mn, Na, K, Zn), trace metals (As, Cd, Cr, Cu, Ni, Pb, Se), nitrate, nitrite, orthophosphorus, total dissolved solids, total suspended solids, total suspended volatile solids, sulfate, total kjeldahl nitrogen, total organic carbon, water, total phosphorus, and turbidity. The Ohio EPA Division of Environmental Services (DES) analyzes all water quality characteristics. Additional parameters can be added. For example, Buckeye Lake and Grand Lake have additional parameters including low-level orthophosphates, chlorophyll a, phytoplankton, and cyanotoxins, which are also analyzed by the DES.

To gather data on a continuous basis, Ohio EPA has built a wooden structure on Buckeye Lake to house two multi-parameter probes. These probes collect physical water quality data and are powered by a solar charged battery. The probe took measurements of depth (m), temperature

13 (˚C), pH (SU), conductivity (µS/cm), dissolved oxygen concentration (mg/L) and turbidity (NTU) and calculated dissolved oxygen saturation (%) and specific conductivity (µS/cm) (Ohio EPA, 2015a). Data are sent wirelessly to a website where it was monitored for maintenance. Out of range data could indicate that cleaning and calibration were needed. Upkeep of the probes occurred about every two weeks.

During my internship I was responsible for sampling water chemistry, phytoplankton, HABs, physical parameters, Secchi depth, and total water depth. I also assisted in sampling for quality control. Maintenance of the probes on the field station was another task that I sometimes helped with.

Water chemistry sampling occurred at three sites (Table 4) from April – September. Sampling events occurred at least every two weeks but often times even more than that in the peak of the season in the middle of summer. At the deepest sampling site, samples were a composite of the surface, mid-column, and 0.5 meters off the bottom of the lake. Mid-column samples were taken using a Van Dorn sampler at the other sites due to shallowness (Ohio EPA, 2015a). Samples were tested for parameters listed in Table 3.

Whole water phytoplankton enumeration and HABs were sampled using a two-meter vertical integrated tube sampler. Specific physical parameters including temperature (˚C), dissolved oxygen concentration (mg/L), pH (S.U.) and conductivity (µS/cm) were measured using a multi parameter field meter at 0.5 m increments (Ohio EPA, 2015a). Dissolved oxygen saturation (%) and specific conductance (µS/cm@25˚C) were calculated by the sonde. Secchi depth and total water depth are also measured at each site but to expedite sample-processing time, metals were not tested.

Field duplicates, field blanks, and equipment blanks were collected at a frequency of five percent. Quality control was also established by testing new lots of acid before using them to preserve samples and by calibrating field meters per the manufactures guidelines. All sampling and measurements followed the Ohio EPA Surface Water Sampling manual (Ohio EPA, 2013d).

14 Table 3 Parameters analyzed in water column samples (Ohio EPA 2015 Buckeye Lake Study Plan)

Parameter Method Reporting Limit Container Preservatives

Alkalinity USEPA 310.1 5 mg/L 1 L LDPE 5 ml H2SO4 Carbon, Total SM 5310B 2 mg/L 4 L LDPE N/A Organic CBOD20 OEPA 310.2 3 mg/L 4 L LDPE N/A Chloride USEPA 325.1 5 mg/L 1 L LDPE 5 ml H2SO4 Nitrate SM 4500-NO3-D 0.5 mg/L 1 L LDPE 5 ml H2SO4 Nitrite USEPA 353.2 0.02 mg/L 1 L LDPE 5 ml H2SO4 Nitrogen, Total USEPA 351.2 0.2 mg/L 1 L LDPE 5 ml H2SO4 Kjeldahl Orthophosphate USEPA 365.1 0.1 mg/L 125 ml glass jar Filter/ N/A Solids, Total SM 2540C 10 mg/L 4 L LDPE N/A Dissolved Solids, Total SM 2540D 5 mg/L 4 L LDPE N/A Suspended Sulfate USEPA 375.2 5 mg/L 1 L LDPE 5 ml H2SO4 Total Phosphorus USEPA 365.4 0.01 mg/L 1 L LDPE 5 ml H2SO4 Chlorophyll a + USEPA 445 0.05 mg/L GC Glass Filter Filter, MgCO3 (Pheophytin)

Table 4 Sample Locations (Ohio EPA 2015 Buckeye Lake Study Plan)

Station Name Station ID # North Latitude West Longitude L -2 300412 39.93055 82.46449 L - 1 203886 39.92930 82.43960 L - 3 301483 39.1150 82.50859

In Grand Lake St. Marys physical water quality was measured in the lake using the same multi-parameter probe as the other studies lakes and at the same time as the water chemistry grab samples were collected. Data were recorded and entered into the Ohio EPA EA3 data management system. Water chemistry samples were collected once in May, July, and September. Water chemistry was analyzed for the parameters in Table 5. Water chemistry samples were collected at a depth of 0.5m using a Van Dorn sampler and placed into collapsible 1L low- density polyethylene (LDPE) containers. This depth was also used to perform phytoplankton enumeration. Three separate sampling locations were used and are listed in Table 6. Field duplicates were also collected at a frequency of five percent. Field blanks and equipment blanks combined were collected at a frequency of five percent as well.

15 Table 5 Parameters measured for Water Chemistry (Ohio EPA Grand Lake St. Marys 2015 Study Plan)

Parameter Method Reporting Limit Container Preservative Alkalinity US EPA 310.1 5 mg/L Bicarbonate SM 2320 B 5 mg/L Total Dissolved SM 2540 C 10 mg/L Solids Total Suspended SM 2540 D 5 mg/L Solids 1L LDPE Cool to 4˚C Total Volatile SM 2540 D/E 5 mg/L Suspended Solids Chloride US EPA 325.1 5 mg/L Turbidity US EPA 180.1 0.05 NTU Sulfate US EPA 375.2 5 mg/L Total Ammonia US EPA 350.1 0.05 mg/L (as N) Total Nitrate + US EPA 350.1 0.1 mg/L Nitrite (as N) Total Nitrite (as USA 353.2 0.02 mg/L N) 2ml H SO cool 1L LDPE 2 4 Total Kjeldahl US EPA 351.2 0.2 mg/L to 4˚C Nitrogen (as N) Total Organic SM 5310 B 2 mg/L Carbon Total Phosphorus US EPA 365.1 0.01 mg/L (as P) Orthophosphate US EPA 365.1 0.01 mg/L 1L LDPE Filter, cool to (as P) 4˚C Chlorophyll a US EPA 445.0 0.05 µg/L GF/C filter MgCO3, freeze

Table 6 Sample Locations (Ohio EPA Grand Lake St. Marys Study Plan)

Station Name Station ID # North Latitude West Longitude L -2 203758 40˚31’34” 84˚33’21” L - 1 203761 40˚31’41” 84˚29’16” L - 3 203764 40˚31’48” 84˚25’54”

Sampling was performed on these lakes to monitor HABs. Establishing years of data is useful for understanding how HABs function and will hopefully one day lead to the discovery of the cause of toxin production and therefore the management to prevent toxin release. The Ohio EPA will likely continue these monitoring programs for a more complete data set.

16 Chapter 3 Inland Lakes & Tetra Tech Study

Outside of special water quality projects like Buckeye Lake and Grand Lake St. Marys, lakes typically fall into the more generic inland lakes sampling category. The term “inland lake” can be somewhat ambiguous but generally refers to lakes with standing water that can vary in size, configuration, water chemistry, and biota (Wisconsin DNR, “Inland Lakes”). The sampling methods described for this lake is the standard or default for lake sampling in Ohio. The parameters are typically consistent as well as the specific manner they are sampled. The sampling procedure outlines how the EPA samples and therefore the way I sampled during my internship.

Lake assessment began in 1989 for the Ohio EPA when a Clean Water Act Section 314 Lake Water Quality Assessment grant provided funding for the monitoring of over 50 lakes. Other grants in the following years allowed assessment of 89 more lakes through 1995 (Ohio EPA, “Inland Lakes Program”). By the next year 447 public lakes greater than 5 acres in surface area were assessed in Volume 3 of the 1996 Ohio Water Resource Inventory (305(b) report) (Ohio EPA, “Inland Lakes Program”). Lake health and beneficial use status was determined with the EPA’s newly developed Lake Condition Index (LCI) (Ohio EPA, “Inland Lakes Program”). At this point dedicated U.S. EPA funding for lake monitoring ended and the Ohio EPA monitored 53 over the next 10 years (Ohio EPA, “Inland Lakes Program”).

Credible data refers to data collected by a third party that are scientifically sound and conform to the Ohio EPA requirements. The Ohio EPA uses these data in different ways depending upon how the data were collected and whether the data meet various review standards (Ohio EPA, “Ohio Credible Data Program”). Three broad categories or levels of data exist that are deemed credible for differing purposes. The LCI assessment process utilized both level 2 and level 3 credible data to make impairment decisions. The statuses decided previously were no longer valid after the passage of Ohio’s Credible Data Law (House Bill 43 (amended), effective 10/21/2003). This law requires that all decisions of impairment for surface waters use only level 3 credible data (Ohio EPA, “Inland Lakes Program”).

The Ohio EPA explored ways to once again launch a lakes monitoring program in 2005. The Ohio EPA participated in the U.S. EPA sponsored National Survey in 2007. 19 Ohio lakes were selected through a probability-based random selection process (Ohio EPA, “Inland Lakes Program”). This participation served to reinitiate Ohio’s lake sampling program.

The survey of the Nation’s Lakes is a statistical survey of the condition of the nations lakes, ponds, and reservoirs (U.S. EPA, 2006). The following text is from the U.S. EPA (2006) reference on the objectives of the National Lake Survey:

• Determine regional and national ecological integrity, trophic status, and recreational value of lakes • Promote collaboration across jurisdictional boundaries • Build state and tribal capacity for monitoring and analyses • Achieve a robust, statistically-valid set of lake data for better management • Develop baseline information to evaluate progress

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The survey aimed to address the question of what percent of the Nation’s lakes are in good, fair, and poor condition for key indicators of trophic state, ecological health, and recreation. The determination of the importance of stressors such as nutrients and pathogens was another goal set by the survey (U.S. EPA, 2006).

The sampling design for the survey is a probability based network which will provide statistically valid estimates of the condition of all lakes with known confidence. The parameters measured will be used to evaluate the ecological condition, trophic state, and recreational potential of lakes (U.S. EPA, 2006).

In 2008, the Ohio EPA once again began to monitor inland lakes. The following list of lake monitoring objectives is from the Ohio EPA’s “Inland Lakes Program” reference:

1. Track status and trends of lake quality 2. Determine attainment status of beneficial uses 3. Identify causes and sources of impaired uses 4. Recommend actions for improving water quality in impaired lakes

Based on available resources, the Ohio EPA annually monitors about 16 lakes per year (Ohio EPA, “Inland Lakes Program”). Inland lakes are prioritized based on certain characteristics. The lakes most critical to sample include those that are thought to be impaired for public drinking water use or impaired for use of recreation. Other considerations include lake within watersheds where TMDL field sampling is occurring and other programmatic needs. Developing a more robust sampling program, sampling a wider variety of lakes, the implementation of the use of remote sensing, and studying how watershed management plans are affecting waters impaired by nonpoint source pollution. Unfortunately these secondary priorities are not currently being addressed due to limited resources (Ohio EPA, “Inland Lakes Program”).

Lake Sampling Procedures

During my internship I assisted in the sampling of seven inland lakes. For each of these lakes a specific protocol was followed. The general protocol is described in this section. Certain lakes used modified protocols either by adding or removing certain parameters described here.

Sampling should occur from May to September. The first sampling location (L-1) is usually the deepest location or the midpoint of the lake (Ohio EPA, 2015c). Additional sampling locations may be necessary but do not necessarily correspond to any specific part of the lake. Reasons additional samples could be needed are size of the lake, if trophic status varies within the lake, major inflows, sub-lake units, or public water system intakes (Ohio EPA, 2015c).

Multi parameter sondes or other meters used to measure field parameters must be calibrated according to manufacturer recommendations no longer than 24 hours prior to sampling of the lake (Ohio EPA, 2015c). To adequately assess the lake profile, the first measurement should be taken 0.5 m from the surface, the second at 1.0 m and then at 1.0 m intervals or 0.5 m in lakes with a depth less than 7.0m. Final readings should be taken approximately 0.5 m from

18 the lake bottom. The probe should be weighted to be kept vertical in the water column but precautions should be taken not to submerge it in the sediment, as readings would be in error.

Secchi depth measures water clarity or turbidity. This reading is taken by lowering the disk into a shaded area outside of direct sunlight. The disk is lowered and the rope is marked at the point at which no part of the disk is visible. The disk is then lowered an additional foot and then slowly brought back up. The line is marked at the point of reappearance. The Secchi depth is the midpoint of the point of disappearance and reappearance. This measurement should be taken between 0900 and 1600 hr. (Ohio EPA, 2015c).

Routine monthly water samples are taken from 0.5 m below the surface and 0.5 m above the bottom and tested for multiple parameters. This is independent of lake stratification. Samples at specific depths are taken with a discrete sampler (Van Dorn style). This type of sample is referred to as a grab sample. Containers are filled if a single grab contains enough water. Otherwise multiple grabs are placed in a churn splitting device. At each depth, 3 one-quart size Cubitainers (Low Density Polyethylene) are filled with sample and appropriate preservatives are added if necessary. Samples should be cooled and preserved according to the most recent Ohio EPA QA/QC manual (Ohio EPA, 2015c).

Low-level phosphorus (total and ortho) is generally only for surface samples. Jars need to be rinsed with nanopure water. Total phosphorus is not filtered and preserved with H2SO4. Preservatives need to be added promptly to the sample within 15 minutes (Ohio EPA, 2015c). The ortho phosphorus sample is filtered and not preserved. A 60 ml polypropylene syringe with Luer-Lock tip and Whatman 0.45 u GM/F is used to filter the sample. The syringe is rinsed with 60 ml of nanopure 2 times. The third rinse should be pushed out through the filter. The filter is then removed and the sample is drawn up and then the filter is re attached to the syringe and the sample is filtered (Ohio EPA, 2015c).

Atrazine is only collected at public water supply lakes and is a common parameter for reservoirs. Atrazine is in the triazine class of herbicide and is used to control broadleaf grassy weeds (U.S. EPA, 2016). This sample is collected 0.5 meters below the surface unless otherwise specified (Ohio EPA, 2015c). The ELISA method is used for all year 1 sampling. In the second year the ELISA method is used again if the maximum atrazine concentration in year 1 was less than 1.5ug/L. If it was greater than that threshold, samples are collected using the herbicide 525.2 method. This method requires a total of two 1 L amber jars preserved with sodium sulfite and HCL (Ohio EPA, 2015c).

Other organics such as semi volatiles, PCBs, etc., not part of the standard inland lakes sampling template, are occasionally collected if determined to satisfy objectives outside of routine assessment for lake habitat use (Ohio EPA, 2015c). Circumstances that may require sampling of this kind include lakes where there may be an issue with a drinking water source, where there are known impairments for fish tissue consumption, or where contaminated sediment exists.

Grab samples are common for chlorophyll a analysis but pumps can also be used. Samples should be collected at a depth of 0.5 m. The volume of water needed for filtration

19 depends upon the unique characteristic of the lake and the particulate load of the water. The volume filtered should be enough to create a noticeable discoloration of the filter, usually green, grey, or brown. Volumes of 100 to 200 ml of sample water are generally required to achieve this discoloration (Ohio EPA, 2015c). Collected samples are stored in brown opaque bottle and on ice until filtered. Filtration is to be performed in subdued light and as soon as possible to avoid errors resulting from algal growth after the fact.

A pressure of 15 cm Hg or persist longer than 10 minutes should not be reached during filtration with a hand pump since these conditions could harm the cells (Ohio EPA, 2015c). MgCO3 is used to preserves the chlorophyll and is especially important when the sample is collected from an acidic lake.

Samples for phytoplankton and cyanotoxin analysis are both collected using an integrated tube sampler, which can be seen in Figure 6 below. This method is useful for a vertical collection of a whole water sample. This is important for these organisms since they stratify through the water column. The bottom of the sampler should be deployed to twice the depth of the Secchi depth and to 2 m if the Secchi depth is greater than or equal to 1 m (Ohio EPA, 2015c). The sampler is rinsed and then lowered to the proper depth at which point the rubber stopper is placed on the top of the sampler. The sampler is raised so that the bottom of the sampler is just below the water surface and then the valve is closed. The sampler is rolled to mix and then dispensed through the spigot.

Figure 6 Using a tube sampler in Buckeye Lake (Source: Ohio EPA)

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Cyanotoxin samples are taken this way and then dispensed into the appropriate containers. 125 ml polyethylene terephthalate glycol (PETG) containers are used for microcystin/ cylindrospermopsin samples. This sample is non-preserved. Saxitoxin is a neurotoxin produced by some algae and cyanobacteria. Samples for saxitoxin analysis are placed in a 40 ml vial pre dosed with preservative. Cyanotoxin samples must be protected from sunlight and cooled on ice after collection.

Phytoplankton are measured by density (cells/L) and bio-volume (µm3/L). Samples are typically taken on odd numbered sampling trips (Ohio EPA, 2015c). Water samples from the tube sampler are composited into the churn splitter (Figure 7) and then a sub sample is dispensed into a glass 125 ml jar and preserved with roughly 0.7 ml of stock Lugol’s solution per 100 ml sample. The final preserved sample should be the color of weak tea. If there is an abundance of algal biomass, more Lugol’s may be needed.

Figure 7 Samples composited in a churn splitter on Buckeye Lake (Source: Ohio EPA)

Zooplankton are free-floating aquatic microorganisms that encompass a wide range of organisms. They are also collected for inland lakes. It is important to sample these organisms since they are an intermediate species in the food chain and are sensitive to changes within the ecosystem (U.S. EPA, 2015). These samples are typically taken on the first, third, and fifth sampling event per year at the L-1 location. In order to collect a zooplankton sample an 80- micron Wisconsin plankton net is needed with 12 cm diameter opening. After the net is properly

21 cleaned and attached to the line and collection bucket it is lowered at a constant speed so that the mouth of the net is 0.7 m above the lake bottom. The net is reeled back in at a steady constant rate of about 0.3 m or 1 ft. per second. At the surface the sides of the net should be rinsed so that the contents are directed to the collection bucket. Care should be taken not to add water the top of the net so that the sample is misrepresented (Ohio EPA, 2015c).

Once the contents are sufficiently rinsed down into the bucket, the bucket is placed into a 500 ml container filled ¾ full with lake water to which a CO2 tablet has been added. The CO2 anesthetize the zooplankton so that they are preserved in a relaxed state. This is important for taxonomic identification. The sample is rinsed into a 125 ml graduated glass sample jar and use ethanol to create a 70% ethanol solution.

E. coli is a fecal coliform and is and indicator for sewage or animal waste contamination in water. These samples are most important when water resources are used for recreational activity. The Ohio EPA samples bacteria when level 3 credible data are not already being collected by another party (Ohio EPA, 2015c). L-1 should be sampled if the lake is used for any open water recreational activity. Additional samples should be taken where there is potential for human contact with water such as a beach or boat ramp. Bacteria sample containers are inverted and submerged to a depth of 1 ft. The sample should be free of sediment and algae. The container is quickly turned upright and removed from the lake. Secure cap and preserve on ice immediately.

Another component of the lake that the Ohio EPA samples on occasion is sediment. Sediment is sampled using a dredge (either Ponar or Eckman samplers). If the sediment screening for BNAs, pesticides, and PCBs turns up parameters concerning to human health, then the water column should be tested for those same parameters.

Tetra Tech

Tetra Tech is a private consulting company that addresses both private and public projects. Near the end of summer, CDO took part in a study with Tetra Tech. As part of my internship I was able to participate in this study. The U.S. EPA is assisting the state’s nutrient reduction effort. Lakes that are public water supplies have been targeted. Tetra Tech has compiled data and generated reports with management plans for certain Ohio lakes. The goal of the project was to monitor and report on the condition of three Ohio inland lakes.

Table 7 Tetra Tech Study Lakes and Locations

Lake County Lake Alma Vinton Kiser Lake Champaign Rose Lake or Hocking Hills Reservoir Hocking

The samples were to provide insight on the contributing watersheds, the physical dimensions, and the chemical conditions of these lakes. The information was taken to provide

22 Tetra Tech the basis to generate recommendations for lake management in terms of recreation and drinking water (Tetra Tech, 2016a).

The surrounding watersheds of these lakes were to be examined using GIS and other geographical sources to identify the contributing land use and point source dischargers. Efforts to collect bathymetry and lake morphology data were taken except for Kiser Lake which data of this kind already exists. A GPS enabled depth finder was used to record geographical coordinates and associate them with lake depth. Transects made in this fashion would create a generalized depth profile of each lake.

Water chemistry was sampled in late summer and early fall 2015 to determine water quality. There was to be at least two sampling events in each lake during the months of September and October 2015. The exact dates were determined based on staff resources and laboratory capacity. With the unique circumstances of the state parks these lakes lie within, notification to the appropriate park staff was important.

Water column samples were taken 0.5 m from the surface and 0.5 meters off the bottom of each lake and follow the Tetra Tech sampling protocol. Tributary samples were to be taken in high flow conditions if possible. The chemical parameters analyzed for lake and tributary samples follow the Ohio EPA Inland Lakes Tribs Ohio EPA, Division of Environmental Service analysis template.

Outside of the water chemistry samples, another sample was taken using the integrated tube sampler. This sample was analyzed for whole water phytoplankton enumeration. In situ measurements of temperature, dissolved oxygen concentration, pH, and conductivity were made at 0.5 m increments using a multi parameter field meter. The meter also recorded dissolved oxygen saturation and specific conductance. Secchi depth and total water depth were also measured at each sampling site. QA/QC protocol was followed from the inland lakes sampling procedure manual.

Lake Alma

Lake Alma lies within Lake Alma State Park. This lake has a surface area of 60 acres (ODNR, “Lake Alma State Park”). The mean depth of the lake is 2.5 meters and there are 1.5 miles of peripheral shoreline. This lake is located within Vinton County and borders Jackson County in southern Ohio. The park is located approximately 60 miles southwest of Columbus (Tetra Tech, 2016a). The lake has a small island with 0.5 miles of shoreline. Only non-motorized boats are permitted on the lake.

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Figure 8 Lake Alma State Park (ODNR Division of Ohio State Parks)

In 1901 the Little Raccoon Creek was dammed to form the lake. In 1903 an amusement park was built on the island. The lake was eventually purchased by the city of Wellston for a municipal water supply. Currently the city leases the area to the ODNR Division of Parks and Restoration for operation as a state park and withdraws water to treat for drinking water. This park is within the unglaciated region of Ohio and the Appalachian Plateau.

The Lake Alma watershed is 455 acres and the largest land use is mixed oak forest at 71%. The lake and park make up 17% and cropland makes up 7% (Tetra Tech, 2016a).

The US EPA is providing technical assistance to Ohio to assist with nutrient reduction efforts in the state, especially to reduce the frequency and impact of HABs in inland lakes with a priority for lakes that are sources for drinking water (Tetra Tech, 2016a). As part of that effort Tetra Tech has developed a conceptual lake management plan for Lake Alma. The lake management plan includes the following (Tetra Tech, 2016a):

• Evaluation of the available water quality data for the lake and its tributaries • Assessment of current data gaps and monitoring recommendations for filling those gaps • Evaluation of the available data relative to the potential for HABs • Recommendations for managing nutrient loads to the lake from the watershed as well as internal loading to the lake to maintain water quality and limit the occurrence of HABs

24 The most recent sampling was conducted in September and October 2015. Previous water quality monitoring efforts include water sampling for algal toxins earlier summer 2015 and during the summers of 2014 and 2013 by the ODNR and the Ohio EPA Southeastern District Office Division of Drinking and Ground Waters. The Ohio EPA also sampled the lake in May and August 1980. At that time they sampled water transparency and surface concentration of chlorophyll and total phosphorus.

After reviewing the water quality data, Tetra Tech developed some recommendations for a future monitoring program that fills gaps in the available data. The recommendations included the following six aspects (Tetra Tech, 2016a):

1. The Ohio EPA should collect samples at least on a monthly basis from March to October. Two sampling events would be most important in the critical growing season months of May through September. Tetra Tech recommends that the standard lake profile be recorded as water samples are collected in addition to measurements of the Secchi disk depth. Water quality samples should be analyzed for the standard water quality assessment of the inland lakes with the addition of total phosphorus.

2. Level loggers should be installed in the lake near the dam and in the outlet structure to obtain accurate records of both lake level and outflow. This would start to fill a data gap and allow for understanding of the water budget and hydraulic flushing rate of the lake that is important for nutrient management.

3. In addition to lake samples, regular water quality samples of the Little Raccoon Creek should be collected. Base flow should typically be sampled with occasional storm events. The same parameters should be analyzed except for chlorophyll.

4. To gain information on the hydrology of the watershed and the water budget for Lake Alma. The Ohio EPA should install equipment to obtain continuous flow data for the small inflow into Lake Alma. These data would elucidate how much surface water enters the lake and will help with nutrient loading estimates from the watershed.

5. DES and an independent laboratory should split at least 20 percent of phosphorus and chlorophyll samples for parallel analysis.

6. An annual aquatic plant survey should be conducted to map the relative community structure, density, and coverage of the macrophytes within the lake to better understand nutrient flows within the lake.

Acquiring additional data for Lake Alma is the most pressing matter. Current data suggest that Lake Alma is moderate or mesotrophic and possibly eutrophic. This nutrient condition could indicate that the lake may be experiencing some water quality issues. As of 2015 no toxic algal blooms have been recorded but these nutrient conditions could make an occurrence more likely. Internal loading of nutrients is suspected in this lake but can’t be confirmed without more data. Consistent sampling will allow comparison of internal loading to the loads of the

25 watershed. Overall more information is needed to make a determination of the trophic state of the lake and how to manage the lake moving forward.

Kiser Lake

Kiser Lake lies within Champaign County approximately 60 miles northwest of Columbus, Ohio. The lake is nearly 2.5 miles in length and has 5.3 miles of shoreline (ODNR, “Kiser Lake State Park”). Kiser Lake has a surface area of 394 acres. It has a mean depth of about 1.9 meters (Tetra Tech, 2016b). The ODNR Division of Wildlife refers to Kiser Lake as “a relatively shallow lake with abundant vegetation, including large areas of lily pads” (ODNR Wildlife, “Kiser”).

Figure 9 Kiser Lake State Park (ODNR Division of Ohio State Parks)

Kiser Lake was created within the Mosquito Valley area. This region was swampy and springs were scattered throughout it (ODNR, “Kiser Lake State Park”). In 1840 a dam was created on Mosquito Creek. The dam was eventually neglected and the lake was mostly lost (ODNR Wildlife, “Kiser”). In 1932 the Kiser family gave several hundred acres of the areas to the state of Ohio. The dam was later reconstructed by 1940, and the lake was named Kiser.

As with may other lakes and areas of Ohio, Kiser Lake has its origins in glacial activity. End moraines created the wooded hills surrounding the lake. The Farmersville moraine surrounds the lake on three sides (ODNR, “Kiser Lake State Park”). Other glacial influences on the area include erratics and the kame fields. Kames are mounds of sand and gravel that were formed by melting glaciers (ODNR, “Kiser Lake State Park). Present day wetland regions also

26 were influenced by past glacial activity. More specifically the wetlands are fens and wet meadows. Large fragments of ice broke off and were covered by sediment. As the covered ice melted it left a water filled depression rich with glacial deposits (ODNR, “Kiser Lake State Park”).

The Kiser Lake watershed is approximately 5,332 acres and primarily consists of cultivated cropland at 54% of its land use. The rest mostly consists of forest (21%), hay/pasture (8%), and developed land (7%) (Tetra Tech, 2016b). Grandview Heights is the only large-sized community within the watershed with 70 homes that use on-site sewage systems. There are another 100 homes within the watershed. There is a dairy to the north with about 400 cows (Tetra Tech, 2016b).

Kiser Lake has been monitored primarily by the Ohio EPA in 1977, 1989, 2009, 2010, and in 2015. It was also briefly studied by Kent State University in 1989 and was part of the National Lakes Assessment in 2007. Lake samples were taken from the main lake station (L-1).

Kiser Lake is a hyper-eutrophic lake with high total phosphorus and chlorophyll. Recently algal blooms have become more common and on occasion have produced toxins. In July 2015, microcystin was detected in samples from the State Park Beach above the Recreational Public Health Advisory concentration (6 µg/ L) and the Recreational No Contact Advisory concentration (20 µg/L) (Tetra Tech, 2016b). Only a public health advisory was issued because there were no reported probable cases of human illness or pet deaths as a result of the bloom. This was the first bloom to trigger a health advisory (Tetra Tech, 2016b).

Tetra Tech compiled and analyzed the available data from Kiser Lake and its tributaries. From this process they were able to determine gaps within the data that would be critical for management of the lake for both water quality and recreation. Tetra Tech created recommendations for water quality monitoring and nutrient management. The recommendations for future water quality monitoring were similar to that for Lake Alma (Tetra Tech, 2016b).

1. Collect samples twice monthly from March through October. 2. Install and operate level loggers on the dam and outlet to collect lake level and outflow data. 3. Collect monthly water quality samples in the major tributaries to Kiser Lake. 4. Install equipment to obtain continuous flow data for Mosquito Creek. 5. Split at least 20% of phosphorus and chlorophyll samples so that they can be analyzed by an independent laboratory in addition to DES. 6. Conduct an aquatic plant survey be conducted in August to map the relative community structure, density, and coverage of the macrophytes

Tetra Tech also developed strategies for nutrient management in Kiser Lake and its watershed. The watershed strategies were based on the agricultural land use. Nutrient management could be improved by the recommended implementation of 4R practices: Right source, Right rate, Right time, Right place. There should be no direct discharges to the lake from on-site sewage systems in the Village of Grandview Heights. These systems should also be evaluated for operation and maintenance. Increase the acreage of cover crops, no-till, and

27 reduced tillage. Expand use of water quantity management. Increase use of riparian buffers and filter strips along critical streams. Tetra Tech suggests the use of treatment trains with alum at the mouths of tributaries. Phosphorus is intercepted by inactivation with alum before discharging to Kiser Lake. Finally constructed wetlands in conjunction with a storage lagoons or ponds could be used to treat animal wastes.

The lake’s setting in a marsh, its historical nutrient rich water quality, and its quantity of aquatic macrophytes all point to internal loading of the lake. However a low number of phosphorus samples leading to the inability to create a phosphorus mass balance model using both water quality and hydrologic data for the lake and its source waters, means that internal loading can not be estimated (Tetra Tech 2016b). In-lake nutrient reduction strategies may be necessary in Kiser Lake if it is determined that internal loading of phosphorus is contributing to the excess nutrient load and subsequent degraded water quality. The following strategies could reduce the internal loading and is from the Tetra Tech (2016b) reference:

• Dredging – removal of the nutrient enriched layer of sediment through dredging is likely the most long-term solution. There are some drawbacks with this method including sediment resuspension, cost, disposal, and geological impacts to water storage capacity. • Nutrient Inactivation – Phosphorus inactivation by aluminum sulfate is the most common and successful technique to control sediment phosphorus in lakes and provides long-term control over internal phosphorus loading • Aeration/ Circulation – Typically used for deeper lakes. To determine if this strategy could benefit the lake, more water quality data are needed. • Shoreline Maintenance – Increased vegetation along the shoreline reduce erosion and thereby reduce phosphorus and sediment loading to Kiser Lake • Waterfowl Management – Excrement can be a significant source of phosphorus. This can be avoided with the use of aggressive harassment of the waterfowl, increased riparian vegetation, artificial birds, and prohibiting of feeding. • Aquatic Plant Control – Dense masses of nuisance vegetation can increase the internal phosphorus loading from the sediment. They can be controlled by herbicides, mechanical removal, and physical removal.

Kiser Lake faces potential HABs and compromised water quality and aquatic habitat. Legacy nutrients in the lake and ongoing watershed loading are shaping the lake’s water quality. Additional data are needed to create a phosphorus mass balance. Once this is created the appropriate management strategies can be employed. Some strategies can be implemented immediately such as enhanced public awareness, BMP for nutrient controls, phosphorus inactivation, and water column stripping (Tetra Tech, 2016b).

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Rose Lake

Rose Lake also known as Hocking Hills Reservoir is located in Hocking Hills State Park in Hocking County. It has a surface area of 17 Acres. This lake was formed by impoundment of a stream with the creation of a dam. It has served as the park’s water source since its creation.

Tetra Tech decided not to report on Rose Lake with its pristine water quality since there were only funds available to report on two of the three lakes.

Drinking Water Reservoirs

During the summer of 2014 the CDO sampled two drinking water reservoirs in addition to the larger lakes within the state parks. The reservoirs sampled were the New Concord Reservoir (also known as Fox Lake) and the Cambridge Reservoir. These reservoirs were very close in proximity to one another in east central Ohio.

The New Concord Reservoir is the public water supply for New Concord, Ohio in Muskingum County. This village is home to Muskingum University. The reservoir itself has a 9- acre surface area (Ohio EPA, 1996). The reservoir is used as a water supply and for recreational use. The reservoir was formed by impoundment (Ohio EPA, 1996).

Cambridge Reservoir is located south of Cambridge, Ohio in Guernsey County. It is the public water supply for the city. It has a surface are of 26 acres. The reservoir’s uses are listed as a water supply and recreational. This reservoir was also formed by impoundment (Ohio EPA, 1996).

Both of these reservoirs were sampled using the inland lakes sampling procedure. These lakes were sampled about once monthly during the standard summer months. These water bodies were the only places where I was able to assist with sediment and zooplankton sampling. The sampling for these reservoirs was concluded in 2015, and they will not be sampled in 2016.

29 Chapter 4 Other Water Quality Projects

While water quality monitoring was my primary task during my internship it was not my only task. The Division of Surface Water has many responsibilities in implementing the Clean Water Act. These involve monitoring surface water other than lakes, designating streams within various categories, assessing treatment of wastewater, and regulating discharge into state waters among other things. During my internship I assisted with these other tasks and these experiences are described in this chapter. Storm Water

My role as an intern was primarily focused on water quality, or lake and stream health. While the office was busy during my internship with many routine samplings and more novel fieldwork, there were days when my efforts were better focused on other tasks. The other side of my internship consisted of storm water, more specifically storm water inspections of construction sites in the district.

In the Central District Office there are two positions dedicated to storm water. A large part of their responsibility is to oversee the compliance with the NPDES general storm water permits. There were 4 interns during my internship dedicated to assisting with the assessment of compliance with these permits. Other tasks were to create reports, write letters, and other follow up activities.

Storm water is runoff from land and impervious areas during rain or snow melt (Ohio EPA, “Storm Water Program”). In a completely natural environment most of the rain would percolate into the soil and recharge groundwater. Human activity has established many impermeable surfaces, such as rooftops, pavement, and concrete that block rain from directly entering the earth. With these surfaces in place, the water instead flows quickly into the infrastructure that was built to direct this water elsewhere. In older cities this system was often combined with the sewage system. In normal conditions all of the sewage would be taken to a treatment facility, but during heavy rainfall the system would be overwhelmed and the overflow would be directly discharged into streams or other natural waters. More recently separate storm sewer systems are being utilized to keep storm water and sewage contained and separate even under events with large volumes of water.

In addition to possible sewage discharge into state waters, storm water is typically laden with pollutants in concentrations that could adversely affect water quality. Common pollutants include sediment, nutrients, oxygen demanding substances, acids, toxic organics, heavy metals, surfactants, and thermal pollution (EPA Victoria, 2012).

The National Pollutant Discharge Elimination System (NPDES) is the US EPA’s approach to controlling point sources of pollutants into the environment. This is a permitting system that requires any point source discharge to be regulated.

At the state level, the NPDES requires a permit for all facilities discharging pollutants from a point source to waters of the state (Ohio EPA, “Surface Water Permit Programs”). Any

30 types of industrial, municipal, or agricultural wastewater are considered pollutants. The Ohio EPA has six types of NPDES programs. The following list is from the Ohio EPA (“Surface Water Permit Programs”) reference on NPDES permits:

• Individual – an NPDES permit unique to a specific facility • General – covers facilities with similar operations and wastewater. • Pretreatment – regulates industrial facilities discharging wastewater to publicly owned treatment works • Storm Water – some storm water discharges are considered point sources and require coverage by an NPDES permit. Storm water general permits include coal surface mining activities, construction site storm water, industrial storm water, marina storm water, and small MS4 storm water permits. • Biosolids – Proper disposal of nutrient-rich organic materials may require a permit • Concentrated Animal Feeding Operation – livestock operations meeting certain criteria may require an NPDES permit

By administering a permitting program, the Ohio EPA limits the negative impacts on the state’s water from construction projects. The program achieves this by requiring practices that keep pollutants out of the stream.

Construction sites were our main focus during inspections. Earth movement and soil destabilization is typically a component of construction activities. Sediment is freed up and can be easily eroded. This is especially the case during events involving precipitation. Construction sites impact waters by adding pollutants, especially sediment, to rainwater running off construction sites during construction and by making long-term changes that alter the land morphology and the hydrology and pollutant loading of nearby streams (Ohio EPA, “Storm Water Program”).

Construction projects disturbing 1 or more acres are required to obtain a permit to discharge storm water from the site. Permits are also required for projects less than 1 acre but part of a larger plan of development or sale. Most entities will obtain coverage under the Ohio EPA’s General NPDES permit for Storm Water Discharge Associated with Construction Activities (Ohio EPA, “Storm Water Program”). More specific and strict permits exist for construction within the Big Darby and Olentangy Watersheds.

Certain steps are required to obtain coverage for the general permit for discharge of storm water associated with construction activity (Ohio EPA, “Storm Water Program”). The first step in this process is to develop a Storm Water Pollution Prevention Plan (SWP3) for the proposed project. This document should identify sources of pollution that could impact the storm water discharge from the project site. The SWP3 consists of a comprehensive site description, controls for each construction operation, and approved state or local plans. The second step is to submit a Notice of Intent (NOI). At this point, the Ohio EPA will send an approval letter for coverage under the general permit. Before construction all contractors, subcontractors, and staff must understand the their roles in carrying out the SWP3. Before and as the project commences, the

31 plan should be implemented to the fullest extent possible. As the project is underway, regular inspections of sediment and erosion controls should be conducted.

General Permit OHC000004

The general permit for construction activities, General Permit OHC000004, requires the permitees to provide specific details regarding the project. In this section I have summarized the key components of the permit especially relevant to my internship.

The general permit for storm water discharges authorizes the discharge from outfalls at construction sites and to the receiving surface waters of the state identified in the NOI that meet the specific conditions of the permit. The EPA has determined that there is some allowable reduction of water quality in order to facilitate social and economic development of the state (Ohio EPA, 2013a).

To start the process, an NOI application and appropriate fee must be submitted at least 21 days before the construction is underway. Coverage under the general permit is not effective until approval from the director of the EPA is received. If the EPA is not notified of the permitee’s intent to be covered under the permit and who discharge pollutants to state waters are in violation and are subject to enforcement action. NOIs and SWP3s are public documents and are to be made available to the public. These documents are also to be readily available to local agencies.

Once permitted, permit holders are to comply with non-numeric effluent limitations for discharges from their sites. Effective sediment and erosion controls need to be implemented and maintained on project sites to minimize the discharge of pollutants as much as possible. The following text is from the general permit (Ohio EPA, 2013a):

1. Control storm water volume and velocity within the site to minimize soil erosion 2. Control storm water discharges, including both peak flow rates and total storm water volume to minimize erosion at outlets and to minimize downstream channel and stream bank erosion 3. Minimize the amount of soil exposed during construction activity 4. Minimize the disturbance of steep slopes 5. Minimize sediment discharges from the site. The design, installation and maintenance of erosion and sediment controls should address factors 6. If feasible, provide and maintain a 50-foot undisturbed natural buffer around surface waters of the state, direct storm water to vegetated areas to increase sediment removal and maximize storm water infiltration. If it is infeasible to provide and maintain an undisturbed 50-foot natural buffer, stabilization requirements for areas within 50 feet of a surface water will be complied with 7. Minimize soil compaction and, unless infeasible, preserve topsoil

Another key component of the permit that permit holders need to be cognizant of is stabilization. Soil stabilization has specific time frames that need to be followed to be in

32 compliance with the general storm water permit. The time frames are specified in the following tables.

Table 8 Permanent Stabilization (Ohio EPA, 2013a)

Area requiring permanent stabilization Time frame to apply erosion controls Any areas that will lie dormant for one year or Within seven days of the most recent more disturbance Any areas within 50 feet of a surface water of Within two days of reaching final grade the state and at final grade Any other areas at final grade Within seven days of reaching final grade within that area

Table 9 Temporary Stabilization (Ohio EPA, 2013a)

Area requiring temporary stabilization Time frame to apply erosion controls Any disturbed areas within 50 feet of a surface Within two days of the most recent disturbance water of the state and not at final grade if the area will remain idle for more than 14 days For all construction activities, any disturbed Within seven days of the most recent areas that will not be dormant for more than 14 disturbance within the area days but less than one year, and not within 50 feet of a surface water of the state For residential subdivisions, disturbed areas must be stabilized at least seven days prior to transfer of permit coverage to the individual lot(s) Disturbed areas will be idle over winter Prior to the onset of winter weather

Other effluent limitations of the general permit include discharges from dewatering activities, and pollution prevention measures. All dewatering including discharges from trenches and excavations are prohibited unless managed by appropriate controls. In general, pollution prevention measures should be designed, installed, and implemented and maintained to minimize the discharge of pollutants. This includes activities such as equipment and vehicle washing, exposure of building materials and wastes to precipitation and storm water, and minimizing the discharge of pollutants from chemical spills and leaks (Ohio EPA, 2013a).

All controls indicated in the SWP3 should be implemented on the project site. The controls used are recommended to meet the standards and specifications in the most current edition of the Ohio’s Rainwater and Land Development manual (ODNR, RWLD). Controls are to encompass non-structural preservation methods, erosion control practices, runoff control practices, sediment control practices, post-construction storm water management requirements, surface water protection, and all other controls. All controls are to be maintained and repaired in order to ensure continued performance of their intended function. During inspections, all controls except sediment settling ponds are to be repaired or maintained within 3 days of the inspection (Ohio EPA, 2013a).

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Once obtained, coverage under and all conditions of the permit are in effect until a signed Notice of Termination (NOT) form is submitted. This is a required step of the permit. All site inspections and other aspects of compliance should continue until the NOT is submitted. Another key component of end of coverage is that the permittee needs to have maintenance agreement in place to ensure all post-construction BMPs will be have ongoing maintenance. In most cases, sites need to have final stabilization for all disturbed areas (Ohio EPA, 2013a).

Within the permit and among the many resources available, no formal storm water inspection form exists, but there are some points that should be considered while performing an inspection, such as if appropriate sediment and erosion controls are being used on site and if there is evidence of erosion or storm water discharge that is not in compliance. I used the Ohio EPA Intern Guide for my inspections and a summary of these points is included in Appendix A. Antidegradation Categories

The Ohio EPA was awarded supplemental 106 funding (water pollution control) for the 2012 and 2013 fiscal years. The goal was to sample streams within small watersheds draining into the Ohio River and to determine their antidegradation category (Ohio EPA, 2015e). Up to this point the streams were assigned to the State Resource Water (SRW) category but this categorization had been replaced by a tiered system of antidegradation categories that includes (Ohio EPA, 2015e):

1. Outstanding National Resource Waters 2. Outstanding State Waters 3. Superior High Quality Waters 4. General High Quality Waters 5. Limited Quality Water

All waters assigned to the SRW category are considered general high quality waters. The streams sampled in this project are for those SRW streams that there is some information or evidence that suggesting that a category other than general high quality water may be more appropriate and that are close in proximity to one another for ease of sampling (Ohio EPA, 2015e). Streams selected also have unconfirmed aquatic life uses so verification of this usage is an additional benefit.

Sampling consists of three distinct assessments to determine the antidegradation category and aquatic life use (Ohio EPA, 2015e). The biological community was analyzed at each sampling site. Both fish and macroinvertebrate communities were assessed with electrofishing and a qualitative multihabitat composite sample respectively. As part of both assessments the physical habitat was also evaluated. Lastly water quality field parameters were measured. 1-3 site visits were conducted for all sites to measure water temperature, dissolved oxygen, pH, and conductivity.

The water quality field parameters are what the CDO and I assisted with collecting. This was accomplished with a multi parameter data sonde calibrated and maintained according to

34 procedures specified in the Surface Water Field Sampling Manual for water column chemistry, bacteria, and flows.

Figure 10 State Resource Waters 2015 Sampling Sites (Ohio EPA, 2015e)

Results were used to determine the appropriate antidegradation category including: 1) presence of federal or state endangered, threatened, or special concern fish and invertebrate species, 2) number and prevalence of declining fish species, 3) quality of the physical habitat as documented by Qualitative Habitat Evaluation Index (QHEI) scores, and 4) quality of fish and macroinvertebrate communities as reflected with biological index scores and macroinvertebrate narrative evaluations (Ohio EPA, 2015e).

35 Ambient Water Quality Monitoring

The term ambient in this context refers to a stream’s baseline characteristics or a reference or characteristic stream of a region. An ambient site is reflective of locally normal background water quality chemistry unaltered by unusual upstream influences (Ohio EPA, 2015d). Ambient sampling stations are associated with USGS stations. They must also have flow year round, be safely accessible, and be non-duplicative. Ambient sampling sites provide data that capture low, medium, and high flows on the hydrograph. They are useful for calculating background concentrations and loads used in waste load allocations (WLAs) for permits, long term biological and chemical trend analysis, quantifying nutrient loading, and possibly for Water Quality Standard (WQS) development (Ohio EPA, 2015d).

The Ohio EPA has sampled near USGS stream flow gages within the state initially as part of a National Ambient Water Quality Monitoring Network but was eventually worked into DSW’s routine water quality sampling (Ohio EPA, 2015d). In the past water quality was sampled monthly and the macroinvertebrate community was sampled every year. In 2008, water quality samples were reduced and from then on sampled quarterly. This is the least frequently that samples should be taken, and they should be taken at least in the beginning of March, June, September, and December. Sampling evenly throughout the year and the seasons allows data to be collected at varying points across the hydrograph. Macroinvertebrate and fish sampling is carried out on a 5-year rotation and includes sampling at a 4-5 site subset of the ambient site list.

All types of data from the sampling stations are used to track trends in water quality. These data has been beneficial in the past when the Ohio EPA was assessing watersheds for total maximum daily load (TMDL) development. These stations are also important for nutrient sources in relation to HABs and management evaluation (Ohio EPA, 2015d).

Water chemistry will be determined at a specific time in the field with a properly calibrated water quality sonde. Collected data will be both recorded electronically and also recorded on a paper sample submission form. Parameters recorded include temperature, DO (mg/L and %), specific conductivity, and pH (Ohio EPA, 2015d). Water samples will be tested following the DES schedule for stream surveys. Samples are collected either by wading into the stream and directly filling the containers or by using a clean intermediate container. Data are managed in the DSW’s Ecological Assessment and Analysis Application (EA3) program. All sampling follows the guidelines specified in the most current Surface Water Sampling Manual.

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Figure 11 2015 Ambient Sampling Sites (Ohio EPA, 2015d)

Biomonitoring

During my internship I was able to assist with bioassays. We sampled near the Pickaway Correctional Institution wastewater treatment plant and the Big Darby Creek.

Biomonitoring or bioassay conditions are required for NPDES permits in Ohio. This is done to determine the impact or possible impact of wastewater discharge on aquatic life with biological methods. NPDES biomonitoring requirements can be one of two possibilities. One is the evaluation of effluent toxicity through toxicity tests and the other is the evaluation of the impact of effluent through assessment of the instream community.

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The most frequently used form of biomonitoring for the NPDES is toxicity testing using aquatic organisms to directly measure effluent toxicity (Ohio EPA, 1998). Toxicity testing usually involves fathead minnows (Pimephales promelas) and Ceriodaphnia dubia.

The following text is from the Ohio EPA (1998) reference on toxicity testing. There are three types of effluent toxicity testing:

1. Flow-through – the tested effluent is required to be constantly pumped through the test chamber 2. Static – the sample used to initiate the test is the only one used for the duration of the test 3. Static Renewal – the test solutions are required to be renewed daily using the original sample or additional samples collected during the testing period

Duration and intent of the toxicity test are important factors and can yield different types of effects (Ohio EPA, 1998). Acute toxicity tests measure short term, and easily recognizable effects. These typically have durations of 2 – 4 days depending on the test species. End points measured are death or atypical behavior or appearance. Chronic tests measure longer –term and possibly less obvious effects. These test last from the usual 7 days up to longer than a year. The end points are growth or reproductive effects, death, and atypical behavior or appearance.

Instream community assessments are a direct measure of the structure and function of the aquatic community in the receiving water. The resident populations are compared to criteria for minimally impacted aquatic communities established in the Ohio Water Quality Standards (Ohio EPA, 1998).

38 Chapter 5 Reflection on IES Experience

Over the 19 weeks I spent interning with the Ohio EPA, I learned about a variety of things ranging from how the state implements the clean water act to things about myself. Table 10 has an overview of the new skills and knowledge that I gained from this internship. The most obvious things I learned revolved around work related experience. I learned how to accomplish certain tasks such as how to conduct storm water inspections; how to prepare for sampling trips; how to collect, prepare, and deliver samples; and how to manage data within the Ohio EPA.

Table 10 Overview of key knowledge and skills obtained from the Ohio EPA internship

Internship Experiences Knowledge and Skills Obtained General Ohio EPA Structure and organization of the Ohio EPA Lake Monitoring Preparing for sampling trips, sample collection, sample preservation and delivery, data management Stream Sampling Stream categorization systems, sampling strategy Storm Water Conducting storm water site inspections, sediment and erosion control

The Ohio EPA was another main topic I learned about. I learned how the Ohio EPA operates, everything from its structure and organization to the online organization. I grew up 15 minutes away from the northeast district office and didn’t know it existed until now. Things like reserving a vehicle, monthly district meetings, and horizontal transfers of employees between departments became familiar to me. I learned about politics and how they can influence the workplace. From interning with environmental consultants while an undergraduate and this internship with the Ohio EPA, the differences between government and private industry work became more apparent to me.

I also learned about myself including what type of work I might want pursue later in my life and where in Ohio I might like to work. Another thing I took away from the internship was my ability to work with a team or by myself. Most of the time I was working alongside other interns or full time staff. On occasions I would work alone. I didn’t think I would like it, but it wasn’t that bad as long as I had a clear understanding of what I had to do. This position also involved a lot of driving. Either driving back and forth from a lake or stream or during a storm water inspection route. I’m not sure how excited I would be if I knew the extent of my time driving beforehand, but I can say now that I didn’t mind it. I decided that the landscape that makes up northwest Ohio might be too flat for my tastes. I prefer being surrounded by trees and hills are also appreciated. With that in mind, southeast Ohio might be the most aesthetically pleasing region in my opinion.

I was fortunate enough to come into this internship with plenty of applicable experience. My previous experiences not only prepared me for the internship, but also most likely played a large part in making me a competitive applicant and therefore getting me the position in the first place. The IES experiences that helped me acquire and be prepared for the internship were the

39 Professional Service Project (PSP), specific coursework, and the summer internship I held between my first and second year of the program.

A defining and unique part of the IES Master of Environmental Science (M.En.) program is the PSP. This project begins early in the fall of the first semester and concludes the next spring. The project is counted as two classes lasting the first year but in reality it is a bigger commitment and is treated more like a job. Projects are each unique and serve a diverse group of clients in the Oxford and southwest Ohio Area. The number of projects and teams is decided by the size of the incoming class. There were ten students in my cohort, which made two teams of five. In other years there have been more students and three teams is not uncommon.

The PSP I worked on was titled “Stormwater in Oxford: Inventory of Structural Best Management Practices and Recommendations for Effective Outreach and Marketing”. The city of Oxford Environmental Commission was the client and we were creating deliverables for them to help them comply with the first two minimal control measures set by phase II of the NPDES. The team identified structural BMP within Oxford’s corporation limits using interviews and an online questionnaire and then created a GIS map visualizing location and type of BMP. The other part of the project was to “research strategies for implementing an effective stormwater education and outreach program” (PSP, 2014).

This PSP served as my first introduction into storm water. Through the process of creating the report and the related map I learned about all the different types of structures used to mitigate storm water runoff. I also learned about the NPDES and how permits requirements are set and how communities can meet them.

Another important component of the IES program are the concentrations and related courses. There are five concentrations including: Applied Ecology and Conservation, Land and Water Resources, Energy and Environment, Environmental Toxicology and Pollution Prevention, and Sustainability in Management and Planning. My concentration was Applied Ecology and Conservation but I also met the requirements for Land and Water Resources. The Applied Ecology and Conservation concentration gives students the knowledge to pursue careers in the area of conservation or ecosystem management. Course requirements fell into several groupings including Principles of Ecology and Conservation, Landscape and Spatial Analysis, Taxonomic and Field Courses, and Social, Economic and Policy Dimensions. Important courses I took to meet these requirements were Ecosystem and Global Ecology, Limnology, and Environmental Law.

Ecosystem and Global Ecology examined “the interactions among physical, chemical, and biological components that together comprise ecosystems, encompassing the full range of the Earth’s biological diversity (plants, animal and microbes) in both terrestrial and aquatic settings” (BIO 672, 2014). The most important aspect of this class was covering the movement of carbon and cycling of nutrients. This was important because it allowed for an understanding of how nutrients move through a landscape and what role lakes play in an ecosystem. This was a rigorous course with heavy loads of reading and presentations but it was one of the more rewarding classes I took at Miami University. It was taught by three professors, one being Mike

40 Vanni who has spent many years studying lake nutrient cycling and so the class had a special emphasis on that topic.

Dr. Vanni also taught Limnology. This class had some overlap with ecosystem and global ecology especially in nutrient cycling but had its own unique components as well. Unique parts of the course included aquatic ecosystem structure and food webs, physical properties of water, thermal stratification and oxygen distribution, populations, and competition. Leaning about stratification and light attenuation was especially helpful for my internship because we collected water profile data at each sampling location at every lake. The reinforcement of biogeochemical cycles was also helpful especially because the lab portion of the class allowed for more hands on experience. We had an experiment that lasted the whole fall and the ecological research center that centered on nutrient sources and sinks. We were even able to visit Acton Lake and get some experience working off a boat. We took lake profile data with sondes, took sediment samples with, and sample water at specific depths with a Vann Dorn – all sampling methods I would use frequently use during my internship. We also were able to electroshock fish, which was a new experience for me.

The last class that prepared me for my internship with the Ohio EPA was Environmental Law. This course “familiarizes students with basic legal institutions and concepts of the American legal system, outlines the transitions of environmental policy from its common law roots to its modern administrative law form, and gives an overview of the major federal environmental statutes” (IES 450/550, 2014). This class didn’t directly help my understanding of sampling or give me practical field experience, but it did give me critical background information about why the work I was performing was being done in the first place. Before taking this class, I had little experience about environmental law. By taking this class I familiarized myself with the Clean Water Act.

After my first year of the M.En. program I acquired a summer internship with the Clermont County Soil and Water Conservation District (Clermont SWCD). This internship was part time. I typically worked Wednesday through Friday and sometimes earlier in the week when needed. My primary goal was to assist the United States Geological Survey (USGS) monitor HABs in Harsha Lake also known as East Fork Reservoir in the county. On Wednesdays I would spend half the day helping the staff at the SWCD office and the other half calibrating a multi parameter sonde and preparing for sampling the following day. Thursdays I would sample the lake and then process the samples. I processed the samples in a facility used by the county as a laboratory and the US EPA as a stream research facility.

I helped the SWCD staff in a few ways but creating an inventory of storm water infrastructure was what I frequently did. The county was developing a GIS of the entire storm water infrastructure within the county to meet current and possible future requirements of the NPDES. This included all public culverts, manholes, and catchments. GPS location and details on condition, material, direction, etc. were recorded on a handheld GPS unit running an ArcGIS application. The data were uploaded into the GIS and integrated to build a full county level inventory. I also helped in the office to georeference construction plans adding storm water infrastructure.

41 Overall this experience with the county was useful to me in a few key ways. At least one sonde had to be calibrated every week while I helped sample lakes or streams with the Ohio EPA. This was most weeks so being proficient and comfortable calibrating sondes was helpful. Both the USGS and Ohio EPA used yellow spring instrument (YSI) sondes so my experience was transferable. Using sondes and the associated handheld device was also very helpful. The processing I did for USGS was similar to the processing and preservation I did for the Ohio EPA. I would add Lugol’s iodine to phytoplankton to stain and preserve the specimens. I had to add sulfuric acid to nutrient samples. I also had to collect the Secchi depth. Working more closely with storm water also helped me later when I needed to conduct storm water inspections. I was more familiar with the structures and how they worked together to remove storm water off a site after assisting Clermont County.

Before I started this internship I had a general sense of the work I would like to do in the future. This idea was informed by previous internships at environmental consulting companies and the government at the county level. Fist I wanted to help the environment in one-way or another. Protecting or conserving natural resources or wildlife, preventing pollution, and encouraging sustainability were always important to me. I also knew I wanted to have a job that allowed me to work outdoors at least some of the time. I also wanted variability in the work I did. I didn’t want to know exactly what I was going to do two weeks in advance from any point in time. For the most part it seems like both private and government work would support this.

There are some differences between careers in the two sectors. Private companies are said to generally offer better pay. These jobs typically paid on a salary basis and so there is no overtime and long hours may be expected to complete projects or meet deadlines. In contrast the government positions I have been around are paid hourly. The pay may be lower, but once an employee meets the required hours they can go home and leave their work behind. Government work is also said to have substantial benefits. Another difference is the sense of urgency. Because of the salary pay and deadlines, private work is thought to be performed at a quicker pace. There is also competition between private industries that contributes to this. In the government, there is no competition and with the other differences it might appear that this work is completed at a relatively relaxed manner.

Government work at the state level was new to me and it was beneficial to see how that compared to previous experiences. I liked the statewide level of organization and the opportunity to transfer to different districts within Ohio. I appreciated the role the Central District Office seemed to play during my time there. The CDO didn’t have a large stream assessment like it usually did this year and so had a relatively light workload compared to the other district offices. This freed the office up to support the other districts when needed. The central location made this especially convenient. I was able to work in all the districts and this variety was exciting and helped me feel like the state was really being looked after.

I will consider working with the state in the future. It was a great experience and I enjoyed my time there and gained valuable work experience that will help me in any position I have in the future. The Ohio EPA is often reorganizing its divisions and offices to best meet the needs of the state in the most effective and efficient way possible. With HABs in the spotlight it is possible that a new division would be formed with staff from relevant existing divisions like

42 surface water and drinking water. A new division such as that would be an especially exciting place to work.

43 Appendix A

The following list is a summary of the Ohio EPA (2013c) Intern Guide.

• Has the NOI been submitted? A copy of the NOI and the letter granting permit coverage is required to be kept onsite. As stated previously, construction activity is not authorized until the applicant has received a letter of authorization from the director. The NOI may also be a required item for local agencies and it is recommended that a copy be sent to those parties.

• Is the SWP3 being implemented? This document is required to be available onsite during standard business hours. It’s typically not feasible to completely review the document during an inspection but there are some details that can indicate an adequate plan:

o Compare the listed acreage on the NOI with available maps of the project and the actual disturbed area. These items should be in agreement and additional disturbed area needs to be accounted for and properly controlled. o The site map should include 1) limits of earth disturbing activity 2) soil types 3) existing and proposed contours and delineated watersheds 4) surface water on or within 200 ft. of the site 5) existing and proposed locations of buildings and other infrastructure 6) sediment and erosion controls. Sediment settling ponds should include volumes and contributing drainage area 7) permanent storm water management practices to be used to control pollution in storm water after construction operations have been completed 8) areas designate for the storage of solid, sanitary, and toxic wastes 9) floodplain fill, floodplain excavation, any in- stream activity, stream restoration or stream crossings o Detail drawings or specifications must be provided of all control practices with maintenance notes o Construction schedule – when will sediment and erosion controls be implemented in the construction process? o A description of the post-construction BMPs including detail drawings o A written document containing the signatures of a contractors and sub-contractors involved in the implementation of the SWP3

• Permitees are required to perform site inspections that should be documented. Inspections are required weekly and within 24 hours after any storm event greater than a ½ inch of rain per 24-hour period. Inspections must include the assessment of all disturbed areas, material storage areas, all sediment and erosion control measures, discharge locations, and all vehicle access points. Records must include incidents of non-compliance and corrective actions required.

• Off site sediment discharge should be minimized as much as possible. Structural controls must address all runoff from sites that will be disturbed for 14 days or longer. These controls are to be implemented before grading activity and within 7 days from the start of grubbing. They should remain functional until final stabilization. The controls are to remove sediment before the storm water is discharged off site.

44

• Appropriate sediment controls should be used for the right situations. The right control and adequate size depends on the drainage area size and its slope. Analyzing the contours of the site map can check this.

• Inspectors should note the presence of rills, gullies, or weathered soils, and the amount of weed growth. These items can allow you to determine if the disturbed areas exceeded the timeframe for stabilization or the need for erosion controls.

• Inspectors should always observe all construction entrances for off-site vehicle tracking. All access points should be stabilized with a gravel drive underlain with geotextile fabric.

• All sediment and erosion controls should be observed. These controls must be maintained and repaired as needed to assure continued performance of their intended function. Controls should be repaired within 3 days of inspection.

• Inspectors should be aware of any waters of the state in or in proximity to disturbed soil. The placement of controls in waters of the state is not acceptable unless done in accordance with a Section 401/404 permit or isolated wetlands permit. Operation of construction machinery in existing stream channels is not permitted without construction of a temporary bridge or other approved method.

• Permitted discharges are those composed entirely of storm water, uncontaminated groundwater, trench dewatering, and storm water discharges from support activities. Appropriate BMPs must be used to address each of these discharges.

• When construction is nearing to an end and the permanent drainage system is in place, post construction BMPs should be looked for. Measure should also be in place to protect them from excessive sedimentation.

Once the inspection is completed, a letter is written to the operator. This content of the letter depends upon the stage of completion of the construction, the presence of compliance issues, and the severity of these issues. Typical letters outline the compliance issues observed throughout the inspection. If compliance issues are repeated or have a dramatic and direct effect to state waters, a notice of violation could be issued. If the construction is complete, a letter requesting a notice of termination is sent. If no construction has started, a letter describing this is sent. Templates for regular letters, no construction letters, and letters requesting NOTs are provided in Appendix B.

45 Appendix B

Regular Letter Template

DATE

NAME ADDRESS

RE: Construction Storm Water Inspection at _ / _ County Permit Number: 4GC__*AG

Dear NAME,

This letter is written regarding a storm water inspection conducted by _ and _ of the Ohio EPA at Martin Partition located at ADDRESS on DATE. The purpose of the inspection was to evaluate compliance with Ohio EPA’s “General Storm Water Permit associated with Construction Activities.” During the inspection, our staff noted the following issues associated with construction activities at this site:

HEADING

• ISSUES

If you have any question regarding this letter or the inspection, please do not hesitate to contact me at our Central District Office at # or email at EMAIL. A follow up inspection will be conducted to ensure the conditions of the General Permit are met.

Sincerely,

NAME Division of Surface Water Central District Office

46 No Construction Template

NAME COMPANY ADDRESS

RE: Pre-Construction Storm Water Inspection at …/ … County. Permit #: 4GC…*AG

Dear NAME,

This letter is written regarding a storm water inspection conducted by NAME with the Ohio EPA at FACILITY on DATE. The site is located at ADDRESS in CITY, Ohio. It appears construction has not started at this site. Ohio EPA has received and approved this site for coverage under the General Storm Water Permit Associated with Construction Activities. Ohio EPA’s Storm Water Staff will be conducting future storm water inspections to ensure compliance with the General Permit. Please be aware the Agency will be ensuring the following conditions are addressed:

Storm Water Pollution Prevention Plan (SWPPP):

• A SWPPP must be developed specific for this site. The SWPPP must address the implementation and maintenance of the sediment and erosion controls during all phases of construction. The SWPPP must be updated to reflect the potential dynamics of construction activities. Site maps, depicting drainage patterns and the location of all controls must be inclusive in the SWPPP. The SWPPP must be maintained onsite available for review.

Sediment Control Requirements:

• The General Permit mandates the installation of appropriate sediment controls as the first step of construction. If the SWPPP depicts the use of a centralized sediment basin for control, the agency will ensure the basin is installed to control all phases of construction. This directly applies to control prior and following the installation of the storm sewer system. Perimeter controls must be installed and maintained.

Erosion Control Requirements:

• Please be aware the General Permit mandates specific permanent and temporary stabilization requirements. All disturbed areas that remain idle in excess of 14 days must be protected from erosion within seven days of the last earth disturbing activities. All areas of final grade must be protected within seven days. All earth disturbing activities should be clearly logged in your inspection reports to ensure the 14-day / 7-day requirement is not violated.

47 Maintenance Requirements:

• The General Permit requires the permittee to conduct inspections of all sediment and erosion controls every seven days or within 24 hours of a rain event equal to or greater than 0.5 inches. A log of the inspections and resulting corrective actions must be maintained on site available for review. All earth disturbing activities must be clearly documented in your inspection reports to ensure the temporary or permanent stabilization requirements are not violated.

Post Construction Requirements:

• The General Storm Water Permit requires specific post construction water quality treatment for all sites. Guidance regarding the post construction mandates can be found at: http://www.epa.state.oh.us/dsw/storm/CGPPCQA.aspx.Please submit to my attention (email preferred at EMAIL) which practice will be installed at this site to ensure compliance with the General Permit. Please include all design criteria with your submittal.

If you have any questions regarding this letter or the inspection, please do not hesitate to contact me at our Central District Office at PHONE NUMBER or via email address at EMAIL. Follow up inspections will be conducted to ensure the conditions of the General Permit are continuing to be met. Sincerely,

NAME Division of Surface Water Central District Office

48 Notice of Termination Template

DATE

NAME COMPANY ADDRESS

RE: Notice of Termination Inspection at… / … County, Permit Number: 4GC…*AG

Dear NAME,

This letter is written regarding a storm water inspection conducted by NAME and NAME of the Ohio EPA at SITE located at ADDRESS on DATE. The purpose of the inspection was to evaluate compliance with Ohio EPA’s “General Storm Water Permit associated with Construction Activities.”

It appeared during the inspection that construction activity has been completed for this site. A Notice of Termination form is required provided the following items are addressed:

• All areas must be protected from erosion measured by a minimum vegetative density of 70 percent for all disturbed areas.

• The General Storm Water Permit requires specific post construction water quality treatment for all sites. Guidance regarding the post construction mandates can be found at: http://www.epa.state.oh.us/dsw/storm/CGPPCQA.aspx. Please submit to my supervisor’s attention (email preferred at [email protected]) which practice will be installed at this site to ensure compliance with the General Permit. Please include all design criteria with your submittal.

• If the vegetative requirements above are met, please submit your Notice of Termination (NOT) concurrent with your submittal of the post construction verification. The NOT form can be found at: http://www.epa.state.oh.us/portals/35/documents/NOT_app_fis.pdf

If you have any question regarding this letter or the inspection, please do not hesitate to contact me at our Central District Office at PHONE# or email at EMAIL.

Sincerely,

NAME Division of Surface Water

49 Central District Office c: Jeff Bohne, Water Quality Supervisor, DSW/CDO

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